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The American College of Physicians (ACP) Statement on
The CMS Proposal for Complex Chronic Care Management Services

Statement attributable to:
Molly Cooke, MD, FACP
President of the American College of Physicians (ACP)

July 11, 2013

ACP views CMS's proposal to pay physicians for Complex Chronic Care Management Services provided to Medicare patients as a positive development for internal medicine and patient care. The new proposal from CMS is an important and welcome step in recognizing the full breadth of primary care, and of complex chronic care management in particular. The proposal, which is included in the notice of proposed rule-making on the Medicare physician fee schedule, demonstrates the importance that the agency places on primary care, cognitive services, and the Patient-Centered Medical Home model. It follows the path of the agency's other initiatives for primary care, including the Medicare Shared Savings Program, the Pioneer ACO model, the Advance Payment ACO model, the Comprehensive Primary Care Initiative, Medicaid primary care pay parity, and the Medicare Primary Care Incentive Payment Program.

ACP has been working, through the CPT and RUC processes, to develop billing codes and relative values that would account for the non-face-to-face care that internists provide to their patients. The College is encouraged that CMS is building upon this work in proposing to create new Medicare fee schedule codes and relative values to reimburse physicians for the management of patients with complex chronic diseases.

Because CMS recognizes that these are complicated and far-reaching services - beyond any existing Evaluation and Management service - the proposal for coverage is stringent in regard to the requirements for physician practices to be able to bill for the new codes. ACP expects to work with CMS to assure that no unnecessary administrative burdens are placed on physicians and their practices.

ACP is encouraged that CMS is seeking comment on the potential for CMS to recognize a formal patient-centered medical home designation as one means for a practice to demonstrate it has met any final care coordination standards for furnishing complex chronic care management services.

CMS proposes that the codes be considered for the 2015 calendar year, in order to give the agency sufficient time to develop and obtain public input on the care standards. Consequently, there are no proposed relative values for the two chronic-care codes (GXXX1 and GXXX2). ACP expects to work with CMS and the RUC to help establish appropriate relative values for the CCCM codes.

ACP will review CMS's proposal in more detail and will submit specific comments as requested by the agency.

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The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 137,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter and Facebook.